Eason v. State
331 Ga. App. 59
Ga. Ct. App.2015Background
- Eason was convicted by jury of armed robbery and sentenced as a recidivist to life under OCGA § 17-10-7 (a).
- The State’s evidence linked Eason to a Waffle House robbery with co-participants Anderson, Hicks, and Washington.
- Detective Thorp interviewed Eason in custody; his statements were admitted after a Jackson-Denno hearing.
- Eason argued for a continuance, ineffective assistance, admissibility of the in-custody statement, and voir dire issues.
- The trial court denied relief; the appellate court affirmed the judgment on appeal.
- This opinion was decided March 10, 2015, with a concurrence from two judges.
- Notes at end explain witnesses and exhibits related to the trial and the confession.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Continuance request and time to prepare | Eason needed more time to consult counsel | Eason did not properly request a continuance; discretionary denial was error | No abuse of discretion; waiver applies; no reversal |
| Admissibility of in-custody statement | The statement could be influenced by expectation of benefit | No improper inducement; cooperation does not render inadmissible | Statement voluntary; admissible under OCGA 24-8-824 |
| Voir dire of jurors (individual questioning) | Court denied individual voir dire | Court allowed general voir dire with later individualized questions | Procedural compliance; no abuse; permissible under prior cases |
| Ineffective assistance of counsel (overall) | Counsel failed to adequately prepare and investigate | Conduct was strategic; no prejudice shown; multiple subissues fail | No ineffective assistance; insufficient prejudice shown; no new trial required |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes standard for ineffective assistance of counsel)
- Jones v. State, 292 Ga. 593 (2013) (prejudice inquiry requires substantial likelihood, not mere possibility)
- Brown v. State, 288 Ga. 902 (2011) (strong presumptionCounsel's strategic decisions not ineffective per se)
- Shaburov v. State, 324 Ga. App. 743 (2013) (no invocation of right to remain silent; questioning permissible)
- Yancey v. State, 292 Ga. 812 (2013) (failure to object to admissible testimony does not prove ineffectiveness)